Count 6 of the Superseding Indictment reads:

(Depredation of Government Property)
(18 U.S.C. § 1361 and 2)

On or about January 27, 2016, in the District of Oregon, defendants SEAN ANDERSON and JAKE RYAN, aided and abetted by each other, did willfully and by means of excavation and the use of heavy equipment on lands of the Malheur National Wildlife Refuge, property of the United States, injure and commit a depredation against such property, specifically, an archaeological site considered sacred to the Burns Paiute Tribe, resulting in damage in an amount exceeding $1000, in violation of Title 18, United States Code, Sections 1361

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